September 10, 2025

The author of this Update (below) Jesi Carlson is one of the three Feldesman attorneys we engaged recently to facilitate a Webinar for New York State Council members in late July, providing education, updates and information regarding the potential impacts of the amended PRWORA Interpretation, on our services and the individuals who receive them.  

We’ve been following the issue closely since then, updating members as the situation changes.  

Tonight there is some good news for New York and other states that sought an injunction against enforcement of the new interpretation.  A Rhode Island Court judge granted a preliminary injunction stay on  enforcement today. 

One step at a time….

Court Grants Preliminary Injunction Staying the Enforcement of New PRWORA Interpretation in Plaintiff States

By Jesi J. Carlson|Published On: September 10, 2025

On September 10, 2025, the United States District Court for the District of Rhodes Island in State of New York, et al., v. USDOJ, et al., 25-cv-00345 (D. R.I.), granted the States’ Motion for a Preliminary Injunction—with the effect being that the Trump Administration’s new interpretation of “Federal public benefit” under the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) may not be enforced or implemented in the plaintiff states while the case works its way through the judicial system.

The preliminary injunction operates to maintain the status quo in plaintiff states (including New York, Washington, Rhode Island, Arizona, California, Colorado, Connecticut, Delaware, District of Columbia, Hawaii, Illinois, Maine, Maryland, Massachusetts, Michigan, Nevada, Minnesota, New Jersey, New Mexico, Oregon, Vermont and Wisconsin), absent further order of the court.

The court’s order specifically halted enforcement of the following notices:

• U.S. Department of Justice, “Revised Specification Pursuant to the Personal Responsibility and Work Opportunity Reconciliation Act of 1996,” 90 Fed. Reg. 32,025 (July 16, 2025);
• U.S. Department of Health and Human Services (HHS), “Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA); Interpretation of ‘Federal Public Benefit,’” 90 Fed. Reg. 31,232 (July 14, 2025);
• U.S. Department of Education, “Clarification of Federal Public Benefits under the Personal Responsibility and Work Opportunity Reconciliation Act,” 90 Fed. Reg. 30,896 (July 11, 2025); and
• U.S. Department of Labor, “Training and Employment Guidance Letter No. 10-23, Change 2” (July 10, 2025).

The court’s preliminary injunction decision follows a stipulation by the plaintiff states and government in August 2025, which delayed enforcement actions under the new interpretation until after September 10, 2025. Entities within the plaintiff states were eagerly awaiting the court’s decision and were concerned that enforcement could have started as soon as September 11, 2025, without further guidance from the court.

In analyzing the required elements for the preliminary injunction, the court held that the plaintiff states are “likely to succeed” on the merits. In addition, the court construed the notices to be “final agency action,” because they “mark the consummation” of the Agencies’ decision-making about its interpretation of PRWORA’s scope, and may have a “substantial impact” on the regulated entities.

The court specifically identified the following programs (among others) as not covered by PRWORA based on the court’s “best reading” of the statute:

• Head Start;
• The Health Center Program;
• Block grants to the states;
• Programs that have eligibility requirements.

The Administration’s plan for enforcement and/or implementation in states not covered by the court’s order is not currently clear.

As we previously reported, in early July 2025, a handful of federal agencies announced a significant policy change that set forth a revised interpretation of the term “Federal public benefit” as used in Title IV of PRWORA. The notices released at that time provided that any programs serving individuals, households and families would be subject to heightened eligibility restrictions, effective immediately.

Feldesman attorneys will continue to monitor ongoing litigation challenging the Government’s recent changes in interpretation to “federal public benefit” in PRWORA. For questions, please contact Jesi Carlson.

For updates, join Feldesman’s Monthly Briefings for Federal Grantees: Key Updates and Developments webinar. The next sessions in this series will be held on September 16, 2025 at 1 p.m. ET and October 14, 2025 at 1 p.m. ET.